Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Customs seizure under Section 110 turns on whether the proper officer had reason to believe, judged only on the materials available at the time of seizure. Subsequent documents produced by the importer do not determine the legality of the initial seizure, though they may be used in later confiscation proceedings after notice and hearing. On the recorded circumstances-absence of transport documents, quantity and value of the areca nuts, the driver's conduct, and the suspected smuggling pattern-the seizure of the goods was upheld and release of the areca nuts refused. The vehicle, however, was directed to be released to its purported owner after verification and on suitable conditions, including bond.
Customs seizure under Section 110 turns on whether the proper officer had reason to believe, judged only on the materials available at the time of seizure. Subsequent documents produced by the importer do not determine the legality of the initial seizure, though they may be used in later confiscation proceedings after notice and hearing. On the recorded circumstances-absence of transport documents, quantity and value of the areca nuts, the driver's conduct, and the suspected smuggling pattern-the seizure of the goods was upheld and release of the areca nuts refused. The vehicle, however, was directed to be released to its purported owner after verification and on suitable conditions, including bond.
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